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HMRC internal manual

Trusts, Settlements and Estates Manual

HM Revenue & Customs
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Trust management expenses: allowable expenses: specific items: accountancy: obtaining tax advice

Where the tax advice relates to capital gains tax or IHT, the cost is not properly payable out of income, as it cannot be said to relate to income in any way. It is not an allowable TME.

The cost of tax advice is an allowable TME only where it relates directly to the preparation of income tax returns or income tax repayment claims, or where the advice will exclusively benefit income beneficiaries.